ACC Comment Letter on 45X NPRM, Advanced Manufacturing Production Tax Credit 

ACC members welcomed the enactment of the Advanced Manufacturing Production Tax Credit under Section 45X - the credit was viewed as transformative in the onshoring of manufacturing and was the topic of discussions at many companies as decisions were being made on the location of future investments in manufacturing. The credit’s value and the ability to monetize such value tilt the scales in such discussions to investment in the United States, even with strong countercurrents that would favor other countries.

ACC and its members are surprised and disappointed in the Section 45X notice of proposed rulemaking (NPRM) insofar as it announced a significant curtailment in the value of the Section 45X tax credit for those taxpayers producing electrode active materials (EAMs) and critical minerals. The statute states that the value of such credit shall be “10 percent of the costs incurred by the taxpayer with respect to production.”

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American Chemistry Council

The American Chemistry Council’s mission is to advocate for the people, policy, and products of chemistry that make the United States the global leader in innovation and manufacturing. To achieve this, we: Champion science-based policy solutions across all levels of government; Drive continuous performance improvement to protect employees and communities through Responsible Care®; Foster the development of sustainability practices throughout ACC member companies; and Communicate authentically with communities about challenges and solutions for a safer, healthier and more sustainable way of life. Our vision is a world made better by chemistry, where people live happier, healthier, and more prosperous lives, safely and sustainably—for generations to come.